NQA – A Step Up In Document Shredding Certification

by Mollie Day

In the business of handling documents a company couldn’t aim for standards higher than those required by the US nuclear industry. Having a National Quality Assurance (NQA) certificate, the only official certificate recognized by the nuclear industry, is undoubtedly the top credential. Wes Tex Document Inc., a record management company in Lubbock Texas, is currently the only shredding and storage company in the country with NQA status. As nuclear production capacity in the US is projected to increase, the need for qualified document handlers may also be on the rise.

“There are a number of companies doing it [handling documents for the nuclear industry] but there are a lot of complaints,” reports Joe Randazzo, a lead NQA auditor. “If it’s the only game in town you have to go with it,” he adds. Randazzo contracts his services out internationally and to Louisiana Energy Services (LES), a nuclear enrichment facility in Eunice, New Mexico.

Randazzo says LES selected Wes Tex to handle their documents because of the caliber of the company’s work, which was achieved in raising their standards to meet the requirements of the nuclear industry.

The first NQA, the NQA-1, was written originally for the people that design and build power plants. It was intended to be the criteria for upholding the highest standards of safety. The NQA certification is still part of a rigorous protocol required to run a nuclear facility; However, it is not presently required of a document handling company who work with the nuclear industry. It’s the federally-regulated nuclear facility that is responsible for making sure their supplier complies with the law.

When suppliers fall through security’s cracks, then the burden of ensuring the nation’s safety falls upon the nuclear facility. That can mean a lot of extra work for companies like LES who have to answer to the United States Nuclear Regulatory Commission. Mistakes can also be costly for both the facility and their contracted supplier.

After working with Wes Tex through their certification process, Randazzo gives the company a dazzling report, “I am probably more impressed with them than with any company I’ve seen. They weren’t satisfied with being good, they wanted to be excellent.”

Ultimately, according to Randazzo, Wes Tex is doing what any nuclear enrichment facility would want their supplier to do: sticking to the stringent rules required of the nuclear industry. “They have the proper controls in place and they’re using them,” says Randazzo, “We just put it in their hands and we’re trusting they can do it.”

Part of the process of becoming NQA certified, which can take a year or two, involves meeting the eighteen precise procedures stated in the 10 CFR 50, a code of federal regulations for the nuclear industry.

The NQA manual is a company’s training and procedures plan that demonstrates how a company will uphold federal regulations.

“It’s extremely involved,” says Sandra Villa, CEO of SAV Associated Services, LLC., based in northern New Mexico. Villa, whose primary customer is Los Alamos National Laboratory, spent time at Wes Tex analyzing their business, then wrote their NQA manual. In doing her job Villa enabled Wes Tex to refine their services and to meet NQA standards.

“I had to bring formality into their process,” says Villa.

A large part of Villa’s focus in working with Wes Tex was in documentation.

“Formality of documentation is a big element of meeting NQA. You not only have the standards and activities that have to be done to meet the standard, but you have to be able to document it.” Additionally, according to NQA standards, a compliant company has to account for all of its suppliers. When mistakes happen fines can be enforced and clients can be lost.

“You have to understand the whole process,” says Villa.

Villa’s 25 years- plus experience with the process of safe-handling documents for the nuclear industry helps her to anticipate potential pitfalls her clients might encounter. She knows how to avoid conflicts in her own guidance process and in between chapters in an NQA manual. Her knowledge of her subject is vast.

“Error is not acceptable – it doesn’t apply – there’s no such thing in this industry as ignorance,” says Villa, who takes pleasure in doing thing extraordinarily right.

Each individual NQA plan is relative only to a specific company and their particular location(s). In order to become NQA certified a company’s plan must adhere to the American Society of Mechanical Engineer’s (ASME) standards for complying with the 10 CFR 50. In their own manual, the ASME provides requirements and guidelines for the establishment and execution of quality assurance programs. It’s the ASME that defines exactly what a company needs to do in order to meet the standards of the nuclear industry, including but not limited to: design control, organizational structure, procurement control and document control.

John Miller is the president of Wes Tex. As a retired Army Lt. Colonial and homeland security expert Miller has a long history of writing military battle plans and other government-level works. But the founder of Wes Tex says that when faced with the challenge of composing his company’s NQA plan he was wise to hire a nuclear-savvy writer.

In addition to Villa’s expertise, Miller says, his company’s recipe for success is also attributable to a refined collection of the best practices for handling, storing and shredding documents. Compiled in their NQA manual, Wes Tex’s “best of the best” package demonstrates the ultimate in document handling services: The sum whose parts exceed other more general programs, such as NAID and ISO.

Achieving quality isn’t cheap. Miller’s company paid $16,000 to produce the NQA manual that would meet the ASME’s approval, in addition to numerous costs associated with obtaining and maintaining their nuclear vendor status. But according to Miller the NQA status benefits outweigh their costs.

“Having it makes the job a lot easier for our sales reps,” says Miller.

“Requirements of nuclear industry vendors are much more stringent than a purchased trade association certification,” reports Miller. Having NQA status allows Wes Tex to engage with customers like LES. “It positions the company extremely well as a high security service vendor in records management,” says Miller.

NQA certified companies must pass regular evaluations and audits in order to maintain the certificate. That’s in addition to non-stop efforts to demonstrate proof of document control.

“There’s a lot of paperwork,” says Miller.

Wes Tex’s records aren’t limited to just paper. Software also plays a large role in ensuring the company’s performance. Using software and satellite tracking Wes Tex – and their auditors – can keep a close eye on the goods at all times. The company has 24-hour online access to the location of any particular box at every minute. “This is top notch,” say Randazzo.

Part of Wes Tex’s system for document control also includes their fortified FireLock vault, located in Wes Tex’s secure facility. Miller says the vault is equipped with controls for fire suppression, magnetic shielding, alarms, and an ONeil software process for tracking records. Auditors and clients of Wes Tex have online access of continually updated reports of environmental conditions inside the vault.

The vault, like the shredder Wes Tex uses, is the same for every customer. “It’s the nuclear quality assurance program that had to be developed within our company that makes us a stand-alone vendor for this industry,” says Miller.

Wes Tex was well on their way to certification when they took the road to NQA.

“From a security standpoint, we were 75% of the way there before we got started,” says Miller, who was involved for many years with NAID and with homeland security. Past experiences gave him a good head start with the more general processes of handling sensitive documents.

“It was relatively easy for us to complete the process,” says Miller of the remaining 25%. Wes Tex flew through the program, according to their auditor, in about six months.

NQA is not for everyone. It’s not necessary for standard or industrial documents, according to Robert Burns, who is active in the development of nuclear codes and standards such as NQA-1. “If you’re buying something commercial, why would you want to put NQA on it, unless you’re engaged in a standard practice,” says Burns. The ISO 9001 would be more appropriate for industry. NQA is for people who are “really serious” about their practices, he adds.

While it may not be as “easy” for others as it was for Wes Tex to become NQA certified, companies that feel fit-enough to make it, may find the journey to ultimate services well worth their efforts. Reason d’etra might also come from projections regarding the nuclear industry.

The Energy Information Administration (EIA) reports that nuclear power production in the US is projected to increase between now and 2030 due to the nation’s slow but steadily increasing demand for electricity and the higher costs – or scarcity – of other types of fuel.

Burns, who has been involved with nuclear industry for over 26 years, says that the nuclear industry activity is indeed on the rise. “It’s starting to pick up again,” he observes of domestic and oversees nuclear industries. “For the moment we have a significant number of domestic, potential [nuclear industry] clients that are at least putting money up-front to start the design process. We also have a significant business in the upgrades – for the old plants,” Burns reports.

Burns advises that, “It’s the owner-operator of the power plant that members of the shredding industry would want to target.” National laboratories, Burns suggest, would also be a potential clients for an NQA certified company.

With new power plants as well as upgrades to existing plants online for the future, and only one top-notch shredder on the list, the doors to an untapped market are wide open.